CP504 vs. the Final Notice of Intent to Levy
They sound like the same notice and one of them carries a 30-day right the other does not. This is the distinction this site got wrong.
Quick Answer
Two statutes, two notices, one hearing right. CP504 satisfies Internal Revenue Code section 6331(d), which requires written notice before a levy. The Final Notice satisfies section 6330, which is the one that comes with a Collection Due Process hearing. Only the second starts a clock on which a right is lost. The confusion is not accidental: CP504 is titled a Notice of Intent to Levy and the CDP notice is titled a Final Notice of Intent to Levy and Notice of Your Right to a Hearing, and the word "Final" is the only thing between them. This site published the confusion. /notices/cp504/ told readers to request a Collection Due Process hearing on a notice that does not confer one, and it did so on the second most-viewed page on the property. The consequence of the error runs both ways: a reader who thinks CP504 is their hearing notice waits for a right they have not been offered, and a reader who thinks the Final Notice is just another reminder lets a real one expire.
CP504
Advantages
- It is required by statute. The IRS states on its page: "This notice is your Notice of Intent to Levy (Internal Revenue Code section 6331 (d))."
- Section 6331(d)(2) requires the IRS to give written notice at least 30 days before the day of a levy — a waiting period imposed on the IRS.
- The IRS names the Collection Appeals Program as the appeal route on this notice.
- The IRS states no number of days on the page. It says "immediately", four times.
Disadvantages
- It does not confer a Collection Due Process hearing right. Publication 1660 lists the notices that do and CP504 is not among them.
- It can precede one levy without any further notice: a state tax refund, under section 6330(f)(2).
- Its own FAQ sequences things differently from its opening paragraph, and the IRS publishes both.
- It says nothing about Form 12153, CDP, or Publication 1660.
Best For
What it satisfies: the section 6331(d) notice requirement.
Typical Cost
No fee attaches to either notice.
The Final Notice (CP90, CP297, LT11, Letter 1058)
Advantages
- It carries the Collection Due Process hearing right. The IRS states it on the notice itself.
- A timely request prohibits levy while it is pending, unless a section 6330(f) exception applies.
- IRM 5.1.19 states the collection statute is suspended while a timely CDP request runs.
- A determination can be petitioned to the U.S. Tax Court.
Disadvantages
- The right is on a clock and the clock is short. The date is printed on the notice.
- Miss it and what remains is an equivalent hearing, which Publication 1660 states does not prohibit levy and does not suspend the collection statute.
- The IRS issues the same notice under several designations — CP90 and CP297, LT11 and Letter 1058 and Letter 11 — which is itself a source of confusion.
Best For
What it satisfies: the separate section 6330 requirement, which is the one carrying the hearing.
Typical Cost
No fee attaches to either notice.
The Verdict
Two statutes, two notices, one hearing right. CP504 satisfies Internal Revenue Code section 6331(d), which requires written notice before a levy. The Final Notice satisfies section 6330, which is the one that comes with a Collection Due Process hearing. Only the second starts a clock on which a right is lost. The confusion is not accidental: CP504 is titled a Notice of Intent to Levy and the CDP notice is titled a Final Notice of Intent to Levy and Notice of Your Right to a Hearing, and the word "Final" is the only thing between them. This site published the confusion. /notices/cp504/ told readers to request a Collection Due Process hearing on a notice that does not confer one, and it did so on the second most-viewed page on the property. The consequence of the error runs both ways: a reader who thinks CP504 is their hearing notice waits for a right they have not been offered, and a reader who thinks the Final Notice is just another reminder lets a real one expire.
Frequently Asked Questions
Does CP504 give me a right to a hearing?
There is a 30-day period on CP504. What is it?
Can the IRS levy anything after CP504 alone?
How do I tell which notice I have?
Explore More Comparisons
Ready to Take the Next Step?
Use our free tools to determine which option is best for your specific situation.
Sources
- Understanding your CP504 notice — Internal Revenue Service, retrieved 2026-08-21
- Understanding your CP90 notice — Internal Revenue Service, retrieved 2026-08-21
- Understanding your LT11 notice or letter 1058 — Internal Revenue Service, retrieved 2026-08-21
- Publication 1660, Collection Appeal Rights — Internal Revenue Service, retrieved 2026-08-21
- 26 U.S.C. §6330 — Notice and opportunity for hearing before levy — Internal Revenue Service, retrieved 2026-08-21
Sourced to primary IRS materials and editorially reviewed. Not reviewed by a tax professional. Not tax advice. Report a correction.